Actually you cannot include instructions with special interrogatories. Special interrogatories are those you write yourself, while form interrogatories (which have instructions) are written by the judicial council.

The definitions you use in interrogatories are also specially drafted, that is, you create your own definitions for things that must be defined. You can use the definitions on the form interrogatories with your special interrogatories, if they apply.

This response is provided as general information only. It is not intended to be legal advice. Legal advice must be based on the exact facts of the particular situation, and by necessity this forum is not appropriate for discussion of specific, exact facts. Contact a lawyer for more specific advice. My answer to your question on AVVO does not create an attorney-client relationship.

I agree with Attorney Bennett. You don't need instructions because they are prohibited under the Code of Civil Procedure.

If you wish to have definitions within your interrogatories, you need to define them the first time you use the term (and make sure you always CAPITALIZE the defined word throughout the entire set of interrogatories.

The information presented here is general in nature and is not intended, nor should be construed, as legal advice. This posting does not create any attorney-client relationship with the author (who is only admitted to practice law in the State of California). For specific advice about your particular situation, consult your own attorney.

In addition to the fine previous answers, I would only remind you that in a limited civil case you are limited to a 'grab bag' of 35 requests per opposing party. The 35 limit is in total of all things - form rogs, specials, requests for admission, and production of documents.

Yes, I have selected my 35 total. The only thing I am missing is whether or not I need some sort of intro on my Interrogatory page like Comes now, Defendant..... or just beging with Interrogatory No. 1. Thank you.